The regs: Construction products now need CE marking and a declaration of performance
This month Geoff Wilkinson looks at the building regulations that apply to places of public entertainment
One of the most significant changes to the construction industry came into effect on 1 July. Although mainly focused on manufacturers and distributors, the change will have deep-rooted implications for architects, quantity surveyors, contractors and building control bodies. Its impact will be far reaching, yet many of these professionals are unaware of the change.
I am of course referring to the Construction Products Regulation (CPR) which means that construction products will need to be CE marked and accompanied by a declaration of performance (DoP) if it is to be placed on the market in the European Economic Area.
The CPR is intended to open up the market and allow consistent reliable information on the performance of such products. A product’s CE marking will demonstrate that it has an established DoP, which will follow a standard layout and include all relevant information for the product category, helping architects to quickly identify a product’s performance. Comparisons between products should become much easier because the methods of assessment will be consistent.
The scope of the assessment is limited to product characteristics for which there are national provisions relating to the products’ use under the headings:
1) Mechanical resistance and stability
2) Safety in case of fire
3) Hygiene, health and the environment
4) Safety and accessibility in use
5) Protection against noise
6) Energy economy and heat retention
7) Sustainable use of natural resources
Of these, number seven is effectively a new requirement intended to help clarify the claims made about various innovative ‘eco’ products which use new greener raw materials, but which may pose risks due to lack of evidence for long-term reliability and safety. As a result, architects should consider the need to interrogate manufacturers and revisit specification documents to exclude themselves from potential liability claims.
To give an idea of the scale of things there are over 420 harmonised standards for construction products currently in force. However, national provisions can still vary between EU states and so, although a product may be CE marked, it still may not be suitable for particular applications or for use within some states. Its important to recognise that the CPR does not harmonise building regulations or provide recommendations on the suitability of a product for a particular job or required performance level. Responsibility for ensuring the right product is used to comply with Building Regulations remains with designers and contractors.
To add further to the confusion, manufacturers do not need to declare performance for every characteristic of a construction product, only those characteristics for which there are provisions within the list above in relation to the intended use or uses within the EU state where the manufacturer intends the product to be used.
By way of illustration here are some examples of timber product that do and do not require marking.
If that wasn’t confusing enough, my understanding is that manufacturers can continue selling pre-1 July products on condition there are DoPs in line with the CPR and they provide a copy to the client while refraining from using product markings, signs or inscriptions which are likely to mislead. After 1 July, a distributor is still not obliged to withdraw from his shop any construction products received before which were already CE marked in line with the previous 1989 version of the Construction Products Directive and can continue selling these until the stock has been exhausted. Any new delivery of construction products from 1 July, however, must conform, meaning it may not be possible to match products where supplies run out mid-project.
Geoff Wilkinson is managing director of Approved Inspectors Wilkinson Construction Consultants